edge. There was evidence of other financial deals in 1961 from which Bar-tone received income in the amount claimed by the Government. No evidence was offered by appellant.
Much of the Government’s evidence as to Bartone’s financial deals and his connection with Internacionales Servi-cios is based on the testimony of three attorneys. This testimony was admitted over the strenuous objections of appellant who contends it falls within the attorney-client privilege since the attorneys represented him and the corporations involved.
It is true, as appellant contends, that the attorney-client privilege extends to corporations. Radiant Burners, Inc. v. American Gas Association, 320 F.2d 314 (7th Cir. 1963). But, the privilege is not all inclusive. Here, the testimony of the attorneys was limited almost entirely to tracing the transfer of funds to and from Bartone and various corporations. One of the attorneys, who was also Secretary-Treasurer and a Director of Servicios, testified as to the nature and organization of that corporation. There is no indication that any of this testimony concerned legal advice given to Bartone or to the corporations, nor was any confidence disclosed which came to the witnesses through an attorney-client relationship.
The mere fact that a person is an attorney does not render as privileged everything he does for and with a client. Ministerial or clerical services such as those testified to here are not within the privilege.
McFee v. United States, 206 F.2d 872 (9th Cir. 1953); Pollock v. United States, 202 F.2d 281 (5th Cir. 1953). We find no error in regard to admission of the attorneys’ testimony.
By the use of charts and general explanation, a Government agent was permitted to summarize Bartone’s financial dealings in 1959 and 1961. Appellant contends that admission of the summary was error since it included as income to Bartone money which had gone to Servi-cios and other corporations, as well as the Meissner loan.
The use of summaries is not without danger, as the Supreme Court said in Holland v. United States, 348 U. S. 121, 128, 75 S.Ct. 127, 131, 99 L.Ed. 150 (1954): “[B]are figures have a way of acquiring an existence of their own, independent of the evidence which gave rise to them.” Thus, it is necessary that the trial judge carefully examine this type of evidence and supporting exhibits, out of hearing of the jury, in order to determine that everything contained in the summary is supported by the proof. Moreover, the jury should be carefully admonished that a summary is not evidence and has no significance if the underlying evidence is not believed.
The trial court in this case scrupulously examined the proposed summary and charts prior to admission, and thereafter painstakingly and repeatedly cautioned the jury as to their purpose. Thus, there was no error in admission of this testimony and the exhibits. Barber v. United States, 271 F.2d 265 (6th Cir. 1959); Epstein v. United States, 246. F.2d 563 (6th Cir. 1957), cert, denied, 355 U.S. 868, 78 S.Ct. 116, 2 L.Ed. 2d 74 (1957).
Other assignments of error relate to the District Court’s failure to give instructions on certain factors bearing on the appellant’s intent to evade taxes. These concern his alleged belief that he had the right to rely on advice of counsel; that he was entitled to a business deduction for a lost investment; and that as a foreign corporation Servicios was not subject to tax. We have considered these contentions and find them to be without merit.
Complaint is also made of the court’s definition of willful intent. While the instructions could have been more technically accurate on this point, we are of the opinion that when considered as a whole they properly presented